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Bennett Jones LLP

Tax Court Affirms Treaty-Based Canadian Holding Structure

Bennett Jones LLP on

The Tax Court of Canada recently held, in Alta Energy Luxembourg SARL v R, 2018 TCC 152, that a Luxembourg S.A.R.L was entitled to treaty benefits on capital gains and that the general anti-avoidance rule ("GAAR") did not...more

Proskauer Rose LLP

Tax Round Up - April 2017

Proskauer Rose LLP on

Welcome to the Tax Round Up, the first edition of what will be a regular bulletin highlighting the latest tax developments relevant to UK companies and asset managers. We plan to produce this monthly with the next one in...more

Patterson Belknap Webb & Tyler LLP

Entering the U.S. Without Entering Its Tax System: Holding Company Structures for U.S. Operations

Patterson Belknap Webb & Tyler LLP on

Foreign companies entering the U.S. market for the first time will want to consider how their operations can be structured to minimize U.S. taxes. Although sales into the U.S. can be arranged in some cases to keep profits...more

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